Introduction: The Reserve Bank of India (RBI) recently issued a directive, dated January 06, 2024, to all Regulated Entities (REs) regarding the implementation of Section 51A of the Unlawful Activities (Prevention) Act, 1967. The directive specifically addresses updates to the United Nations Security Council’s (UNSC) 1267/1989 ISIL (Da’esh) and Al-Qaida Sanctions List, encompassing amendments in 07 entries.
Detailed Analysis: The RBI’s directive refers to Section 51 of the Master Direction on Know Your Customer, last amended on January 04, 2024. It mandates that REs ensure no accounts exist in the names of individuals/entities listed by the UNSC for suspected terrorist links.
The Ministry of External Affairs (MEA) informed about the UNSC’s press release on January 05, 2024. Amendments were made to entries, including notable individuals like Habib Ben Ahmed Al-Loubiri, Hafiz Muhammad Saeed, Hafiz Abdul Salam Bhuttavi, Maulana Fazlullah, and Noor Wali Mehsud, along with entities such as Al Rashid Trust and Khatiba Imam al-Bukhari.
The detailed profiles of the listed individuals reveal their designations, dates of birth, places of birth, aliases, nationalities, and other relevant information. For instance, Hafiz Muhammad Saeed, leader of Lashkar-e-Tayyiba, is in custody in Pakistan serving a 78-year imprisonment sentence.
Entities like Al Rashid Trust, associated with financing Al-Qaida and the Taliban, have undergone amendments over the years. Despite reported defunct status, the entity’s historical involvement in terrorism financing is outlined.
The RBI emphasizes that REs should adhere to the procedures outlined in the UAPA Order dated February 02, 2021, amended on August 29, 2023, in alignment with Section 51 of the Master Direction on Know Your Customer.
Conclusion: In conclusion, the RBI’s directive serves as a crucial update for Regulated Entities, ensuring compliance with the latest amendments to the UNSC’s ISIL and Al-Qaida Sanctions List. The detailed profiles of listed individuals and entities provide insights into their backgrounds and affiliations. REs are urged to follow the prescribed procedures diligently, considering the gravity of global efforts to combat terrorism. The attached links to UNSC communications offer additional resources for comprehensive understanding and compliance.
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Reserve Bank of India
RBI/2023-24/110
DOR.AML.REC.68/14.06.001/2023-24
January 06, 2024
The Chairpersons/ CEOs of all the Regulated Entities
Madam/Dear Sir,
Implementation of Section 51A of UAPA, 1967 Updates to UNSC’s 1267 / 1989 ISIL (Da’esh) & Al-Qaida Sanctions List Amendments in 07 Entries
Please refer to Section 51 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on January 04, 2024 (MD on KYC), in terms of which “Regulated Entities (REs) shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967 and amendments thereto, they do not have any account in the name of individuals/entities appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).”
2. In this connection, Ministry of External Affairs (MEA), Government of India has informed about the UNSC press release SC/15556 dated January 05, 2024 wherein the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al-Qaida and associated individuals, groups, undertakings and entities enacted the amendments specified with strikethrough and/or underline in the entries below on its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of Security Council resolution 2610 (2021), and adopted under Chapter VII of the Charter of the United Nations.
A. Individuals
QDi.177 Name: 1: HABIB 2: BEN 3: AHMED 4: AL-LOUBIRI
Name (original script): حبيب بن احمد اللوبيري
Title: na Designation: na DOB: 17 Nov. 1961 POB: Manzal Tmim, Nabul, Tunisia Good quality a.k.a.: Al-Habib ben Ahmad ben al-Tayib al-Lubiri Low quality a.k.a.: na Nationality: Tunisia Passport no: Tunisia number M788439, issued on 20 Oct. 2001 (expired on 19 Oct. 2006) National identification no: 01817002 Address: a) Salam Marnaq Ben Arous district, Sidi Mesoud, Tunisia b) Afghanistan Listed on: 23 Jun. 2004 (amended on 20 Dec. 2005, 17 Oct. 2007, 10 Aug. 2009, 13 Dec. 2011, 23 Feb. 2016, 6 Dec. 2019, 19 Dec. 2023) Other information: Italian Fiscal Code: LBR HBB 61S17 Z352F. In detention in Tunisia as at of Dec. 2009. Reportedly fled to Afghanistan in June 2014. Mother’s name is Fatima al-Galasi. Review pursuant to Security Council resolution 1822 (2008) was concluded on 9 Apr. 2010. Review pursuant to Security Council resolution 2368 (2017) was concluded on 4 Dec. 2019 INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
QDi.263 Name: 1: HAFIZ 2: MUHAMMAD 3: SAEED 4: na
Title: na Designation: na DOB: 5 Jun. 1950 POB: Sargodha, Punjab, Pakistan Good quality a.k.a.: a) Hafiz Mohammad Sahib b) Hafiz Mohammad Sayid c) Hafiz Muhammad d) Hafiz Saeed e) Hafez Mohammad Saeed f) Hafiz Mohammad Sayeed g) Tata Mohammad Syeed h) Mohammad Sayed i) Muhammad Saeed Low quality a.k.a.: Hafiz Ji Nationality: Pakistan Passport no: na National identification no: Pakistan 3520025509842-7 Address: House No. 116E, Mohalla Johar, Lahore, Tehsil, Lahore City, Lahore District, Pakistan (location as at of May 2008) Listed on: 10 Dec. 2008 (amended on 17 Jul. 2009, 19 Dec. 2023 Other information: Muhammad Saeed is the leader of Lashkar-e-Tayyiba (QDe.118). In custody of the Government of Pakistan serving a 78 year imprisonment sentence since 12 February 2020 as a result of conviction in seven terror financing cases. INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
QDi.307 Name: 1: HAFIZ 2: ABDUL SALAM 3: BHUTTAVI 4: na
Title: a) Maulavi b) Mullah Designation: na DOB: 1940 POB: Gujranwala, Punjab Province, Pakistan Good quality a.k.a.: a) Hafiz Abdul Salam Bhattvi b) Hafiz Abdusalam Budvi c) Hafiz Abdussalaam Bhutvi d) Abdul Salam Budvi e) Abdul Salam Bhattwi f) Abdul Salam Bhutvi g) Mullah Abdul Salaam Bhattvi h) Molvi Abdursalam Bhattvi Low quality a.k.a.: na Nationality: Pakistan Passport no: na National identification no: na Address: na Listed on: 14 Mar. 2012 (amended on 15 Nov. 2021, 19 Dec. 2023) Other information: Founding member of Lashkar-e-Tayyiba (QDe.118) and deputy to Lashkar-e-Tayyiba leader Hafiz Muhammad Saeed (QDi.263). Confirmed deceased. Review pursuant to Security Council resolution 2368 (2017) was concluded on 15 November 2021. INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
QDi.352 Name: 1: MAULANA 2: FAZLULLAH 3: na 4: na
Title: na Designation: na DOB: 1974 POB: Kuza Bandai village, Swat Valley, Khyber Pakhtunkhawa Province, Pakistan Good quality a.k.a.: a) Mullah Fazlullah b) Fazal Hayat Low quality a.k.a.: Mullah Radio Nationality: na Passport no: na National identification no: na Address: (Afghanistan / Pakistan border region) Listed on: 7 Apr. 2015 (amended on 1 May 2019, 19 Dec. 2023) Other information: Confirmed deceased on 13 June 2018. Commander of Tehrik-e Taliban Pakistan (TTP) (QDe.132) since 7 Nov. 2013. Led the local TTP in Pakistan’s northwest valley of Swat from 2007 to 2009. Review pursuant to Security Council resolution 2253 (2015) was concluded on 21 Feb. 2019. INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
QDi.427 Name: 1: Noor NOOR 2: Wali WALI 3: Mehsud MEHSUD 4: na
Title: Mufti Designation: na DOB: 26 Jun. 1978 POB: Gurguray, Pakistan Good quality a.k.a.: Abu Mansoor Asim Low quality a.k.a.: na Nationality: Pakistan Passport no: na National identification no: na Address: na Lamman, District Barmal, Paktika Province, Afghanistan (as of 26 Nov. 2022) Listed on: 16 Jul. 2020 (amended on 19 Dec. 2023) Other information: Leader of Tehrik-e Taliban Pakistan (TTP) (QDe.132) following the death of former TTP leader Maulana Fazlullah (QDi.352). INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
B. Entities
QDe.005 Name: AL RASHID TRUST
A.k.a.: a) Al-Rasheed Trust b) Al Rasheed Trust c) Al-Rashid Trust d) Aid Organization of the Ulema, Pakistan e) Al Amin Welfare Trust f) Al Amin Trust g) Al Ameen Trust h) Al-Ameen Trust i) Al Madina Trust j) Al-Madina Trust F.k.a.: na Address: a) Kitas Ghar, Nazimabad 4, Dahgel- Iftah, Karachi, Pakistan b) Jamia Maajid, Sulalman Park, Melgium Pura, Lahore, Pakistan c) (Office Dha’rbi-M’unin, Opposite Khyber Bank, Abbottabad Road, Mansehra, Pakistan) d) (Office Dha’rbi-M’unin ZR Brothers, Katcherry Road, Chowk Yadgaar, Peshawar, Pakistan) e) (Office Dha’rbi-M’unin, Rm No. 3, Moti Plaza, Near Liaquat Bagh, Muree Road, Rawalpindi, Pakistan) f) (Office Dha’rbi-M’unin, Top Floor, Dr. Dawa Khan Dental Clinic Surgeon, Main Baxae, Mingora, Swat, Pakistan) g) (Kitab Ghar, Darul Ifta Wal Irshad, Nazimabad No. 4, Karachi, Pakistan, Phone 6683301; Phone 0300-8209199; Fax 6623814) h) (302b-40, Good Earth Court, Opposite Pia Planitarium, Block 13a, Gulshan -l Igbal, Karachi, Pakistan; Phone 4979263) i) (617 Clifton Center, Block 5, 6th Floor, Clifton, Karachi, Pakistan; Phone 587-2545) j) (605 Landmark Plaza, 11 Chundrigar Road, Opposite Jang Building, Karachi, Pakistan; Phone 2623818-19) k) (Jamia Masjid, Sulaiman Park, Begum Pura, Lahore, Pakistan; Phone 042-6812081) Listed on: 6 Oct. 2001 (amended on 21 Oct. 2008, 10 Dec. 2008, 13 Dec. 2011, 6 Dec. 2019, 19 Dec. 2023) Other information: Reportedly defunct. Headquarters are were in Pakistan. Operations in Afghanistan: Herat Jalalabad, Kabul, Kandahar, Mazar Sherif. Also operations in Kosovo, Chechnya. Involved in the financing of Al-Qaida and the Taliban. Until 21 Oct. 2008, this entity appeared also as “Aid Organization of the Ulema, Pakistan” (QDe.073), listed on 24 Apr. 2002 and amended on 25 Jul. 2006. The two entries Al Rashid Trust (QDe.005) and Aid Organization of the Ulema, Pakistan (QDe.073) were consolidated into this entity on 21 Oct. 2008. Founded by Mufti Rashid Ahmad Ledahyanoy (deceased). Associated with Jaish-i-Mohammed (QDe.019). Banned in Pakistan since Oct. 2001. Despite the closure of its offices in Pakistan in February 2007 it has continued its activities. No indication of any activity under the name of Al-Rashid Trust has emerged as of November 2023. Review pursuant to Security Council resolution 1822 (2008) was concluded on 6 May 2010. Review pursuant to Security Council resolution 2368 (2017) was concluded on 4 Dec. 2019. INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals click here
QDe.158 Name: KHATIBA IMAM AL-BUKHARI (KIB)
A.k.a.: Khataib al-Imam al-Bukhari F.k.a.: na Address: a) Afghanistan/Pakistan border area(previous location) b) Khan-Shaykhun, Syrian Arab Republic (53 km south of Idlib, location as at of Mar. 2018) c) Idlib, Aleppo and Khama, Syrian Arab Republic (operation zone) d) Faryab, Badghis and Jawzjan Provinces, Afghanistan Listed on: 29 Mar. 2018 (amended on: 19 Dec. 2023) Other information: Associated with Al-Nusrah Front for the People of the Levant (QDe.137). Committed terrorist attacks in the Syrian Arab Republic. Since 2016 redeployed to Northern Afghanistan to project attacks against Central Asia countries. INTERPOL-UN Security Council Special Notice web link: www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
3. In accordance with paragraph 58 of resolution 2610 (2021), the Committee has made accessible on its website the narrative summaries of reasons for listing of the above entries at the following URL:
www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list/summaries.
4. Press release regarding the above can be found at https://press.un.org/en/2024/sc15556.doc.htm.
Further, the UNSC press releases concerning amendments to the list are available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases
5. The details of the sanction measures and exemptions are available at the following URL: https://www.un.org/securitycouncil/sanctions/1267#further_information
6. In view of the above, REs are advised to take appropriate action in terms of Section 51 of the MD on KYC and strictly follow the procedure as laid down in the UAPA Order dated February 02, 2021 (amended on August 29, 2023) annexed to the MD on KYC.
7. Updated lists of individuals and entities linked to ISIL (Da’esh), Al-Qaida and Taliban are available at:
www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list
https://www.un.org/securitycouncil/sanctions/1988/materials
8. Further, as per the instructions from the Ministry of Home Affairs (MHA), any request for delisting received by any RE is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to be removed from the Security Council’s ISIL (Da’esh) and Al-Qaida Sanctions List can submit their request for delisting to an independent and impartial Ombudsperson who has been appointed by the United Nations Secretary-General. More details are available at the following URL:
https://www.un.org/securitycouncil/ombudsperson/application
9. REs are advised to take note of the aforementioned UNSC communications and ensure meticulous compliance.
Yours faithfully,
(Saidutta Sangram Keshari Pradhan)
General Manager
